ReliabilityFirst Assessed a Penalty of $40,000 for Violation of FAC-008-3 R6

Summary:

ReliabilityFirst identified as part of a Compliance Audit that the City of Lansing by its Board of Water and Light, as a Transmission Owner, was in violation of FAC-008-3 R6. ReliabilityFirst subsequently determined that the violation dated back to FAC-009-1 R1. The Compliance Audit was conducted from December 7, 2020, through December 11, 2020. This violation involves the entity’s failure to establish Facility Ratings consistent with its Facility Ratings Methodology (FRM). The entity’s FRM provided that, for emergency ratings, all transmission lines, including any vertical clearance thereof, should be capable of safely operating at 160C. However, the entity only had evidence to support design to a safe operating temperature of 100C, despite basing its emergency ratings off an operating temperature of 160C. The cause of the discrepancy was a software issue. As part of mitigation, the entity changed its FRM (a) to determine normal and emergency ratings based on a safe operating temperature of 100C and (b) to more clearly account for sag limited ratings based on the minimum allowable clearance to ground or other objects as dictated by the National Electric Safety Code (NESC). Following the changes, the entity was required to remediate thermal rating inconsistencies based on vertical clearance limits for two transmission lines: the Enterprise-Wise line and the Northeast-Willow line. The Enterprise-Wise Transmission Line remained noncompliant with the entity’s methodology for both emergency and normal ratings even after adjusting to a safe operating temperature of 100C and considering the NESC. Therefore, the entity performed fieldwork to assign the line a higher sag limited rating than its interim rating. The average percent derate required was 39 percent. The Northeast-Willow Transmission Line remained noncompliant with the entity’s methodology for both emergency and normal ratings even after adjusting to a safe operating temperature of 100C and considering the NESC. Therefore, the entity performed fieldwork to assign the line a higher sag limited rating than its interim rating. The average percent derate required was 83 percent. The violation began on June 30, 2011, when the entity registered as a TO and was required to comply with FAC-009-1, and ended on March 8, 2024, when the entity updated its FRM and completed the necessary fieldwork to remediate the incorrect Facility Rating for the Enterprise-Wise line.

Additional Discussion:
Cause

The root cause of this violation is multifaceted. First, as to the original audit finding (i.e., the incorrect software setting), the entity failed to implement adequate verification controls. Second, as to the derates required to remediate the thermal violations, the entity’s procedures did not sufficiently account for the particular attributes of field conditions around the Northeast-Willow and Enterprise-Wise lines.

Disposition

ReliabilityFirst considered the entity’s compliance history and determined there were no relevant instances of noncompliance.

ReliabilityFirst recognizes that the cooperation of Registered Entities is vital to maintaining and strengthening the reliability of the BPS. Throughout the lifecycle of this noncompliance, the entity was cooperative and responsive. As such, cooperating credit is being awarded to the entity. A penalty in the amount of $40,000 was assessed.